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2023 (6) TMI 214 - AT - Income TaxDisallowance u/s 14A r.w. Rule 8D - whether assessee has not earned any exempt income? - HELD THAT:- AO has clearly stated that the assessee has not earned from equity investments which would yield exempt dividend income and the dividend income earned by the assessee is NIL. Thus, it is clear that the assessee has not earned any exempt income in the relevant assessment year under appeal against the investments. As relying on M/S CHETTINAD LOGISTICS PVT. LTD. [2018 (7) TMI 567 - SC ORDER]held that when there was no dividend income earned in the relevant assessment year, the disallowance made by the Assessing Officer in view of the provisions of section 14A r.w.r. 8D was completely contrary to the provisions of that section as Rule 8D only provides for a method to determine the amount of expenditure incurred in relation to income, which does not form part of total income of the assessee. Also confirmed by SC [2018 (7) TMI 567 - SC ORDER] - Decided against revenue.
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